brentwood.gov.uk

Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Through appropriate design and landscaping, adverse impacts can be avoided. A 'neutral or depending on implementation' scoring for a number of these criteria would be much more appropriate

We welcome the opportunity to submit representations to the above consultation on behalf S & J Padfield and Partners, who control the land identified as Codham Hall Farm (E10) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E10.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and landscaping, flexibility regarding the delivery of infrastructure requirements, and also the specific wording of the development principles for Policy E10.
The information submitted to the Council was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. The principal change referenced was for amendments to be made to the boundary of the allocation. The application is currently shown with two distinct areas - The existing employment area and some additional land is shown as white land, with surrounding land hatched in green.
In the absence of such detail on a map, or clarity within Policy E10, it is not clear whether the whole site is removed from the Green Belt which is not consistent with national policy or effective. With the majority of the site already being utilised for employment purposes and the whole site not contributing to the Green Belt purposes, it is considered that the site as a whole should be removed from the Green Belt to allow flexibility moving forwards for not only for effective landscaping but also for the security of access arrangements.
We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission.
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Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments should able be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E10.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E10 at pre-submission stage in March made the case that the Codham Hall Farm can be relied upon to deliver a proportion of the Borough's employment land requirement. Whilst none of the focused changes directly impact on the proposed delivery of site E10, the Consultation does provide an opportunity to set out updates on key matters and reiterate the points made through our Regulation 19 representation, including the provision of further clarity on the allocation boundary. Also published alongside the plan are a number of evidence base documents, which we have commented on within this representation.
Infrastructure Delivery Plan
We note that alongside the AFC, other documents comprising the Local Plan Evidence Base have also been updated. The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 29-31 of the document covering the contribution made by the Codham Hall Farm, on top of the employment opportunities that are currently established on the site.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note these measures are listed as Medium to Long term. It is anticipated that employment provision at Codham Hall Farm will commence early in the Local Plan period to provide jobs to support growth in the Borough, particularly as a range of uses are already established.
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We consider the Transport & Movement document should make reference to the potential role that Demand Responsive public transport can play. This is being progressed by parties seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC). The sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which are unlikely to be the solution adopted at Codham Hall Farm.
Additional work is required with regards to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land, and the progression of development on key sites should therefore not be reliant on this from day one.
With regards to specific mitigation measures, other references within the Transport and Movement section relate to access and infrastructure improvements at specific road junctions. Codham Hall North has existing access form the M25 Jct. 29, but is also able to work closely with the Brentwood Enterprise Park site (draft allocation ref: E11) to improve upon the existing arrangement. This can be achieved through a range of options currently being discussed with ECC Highways and Highways England, and we are also in discussion with Planning Officers at Brentwood Borough Council to determine how such improvements can be delivered.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, Codham Hall Farm continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation set out that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We note that the allocation at Brentwood Enterprise Park (E11) is also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of Codham Hall North along the corridor. We note that paragraph 9.6.6 suggests that all sites will have good or excellent access onto the strategic highways network, while the draft plan indicates that access may be achieved via the B186. We note the updates from the version discussed in January that have been made to the October 2019 version finds that they do not lead to significant implications for economy related objections.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,